Preferred Options November 2021

Object

Representation ID: 1437

Received: 10/12/2021

Respondent: Amadis Holdings Ltd

Agent: PlanIt

The housing evidence base which underpins the draft Plan’s housing strategy is deficient. Paragraphs 4.6 to 4.12 of the Preferred Options refers to various evidence base documents that have been used to help identify the
quantum of development for South Staffordshire which will assist in accommodating the unmet housing requirements of the conurbation. None of the documents referred to in these paragraphs are referred to in the evidence base in Appendix A of the draft
Plan. They have, however, been fundamental in shaping the Plan’s housing strategy.
Notwithstanding this omission the proposed housing requirement is unsound. It fails to reflect the most
recent information which is available on the extent of the housing shortfall arising from the conurbation and, in particular, it fails to acknowledge the important role South
Staffordshire must play to support the development needs of the Black Country.

Object

Representation ID: 1438

Received: 10/12/2021

Respondent: Amadis Holdings Ltd

Agent: PlanIt

The infrastructure requirements included within the IDP are based upon the Preferred Options Plan’s housing and employment development targets. It is our view that the emerging Plan makes insufficient provision for housing development. Therefore, the IDP plans for an insufficient level of development. The IDP will need updating in due course if, as we suggest, the housing and employment requirements are increased upwards.

Object

Representation ID: 1481

Received: 10/12/2021

Respondent: Amadis Holdings Ltd

Agent: PlanIt

Vision is inappropriate - the economic objective of sustainable development requires a sufficient quantum of the right type of land to be available to support economic growth. The social objective requires local authorities to ensure that a sufficient number and range of homes are provided to meet the needs of current and future generations. Propose additional text to vision to confirm that South Staffordshire will deliver sufficient land, of the right type, to meet the economic and housing growth requirements of South Staffordshire and which will support the growth of the conurbation.
Strategic Objective , and the Plan as a whole, fail to have any regard to the requirement of the NPPF para 140. Safeguarded land should be identified for longer term development needs.
Strategic Objectives 3, 4 and 5 do not reference providing a sufficient quantum of housing to support the growing number of households in the district to provide enough homes to accommodate South Staffordshire’s working population, or to supporting the growth requirements of the conurbation. Additional Strategic Objective should be added to reflect this.

Support

Representation ID: 1482

Received: 10/12/2021

Respondent: Amadis Holdings Ltd

Agent: PlanIt

Reference to South Staffordshire seeking to strive to protect and enhance its distinctive rural character, communities and landscape; and to create beautiful thriving new places where people can live, work and play is supported. Strategic Objective 6 - Developing an Economic Strategy, is supported. The Plan should seek to retain existing employment and foster sustainable economic growth, encouraging inward investment and job creation.

Support

Representation ID: 1483

Received: 10/12/2021

Respondent: Amadis Holdings Ltd

Agent: PlanIt

In general, we support the approach of Policy DS1 - Green Belt, in so far as it reflects the guidance in the Framework. This is, however, on the basis that the Plan will be amended to remove additional land from the Green Belt to accommodate South Staffordshire’s and the conurbations’ housing and employment needs in accordance with our response to question 5, and land is removed from the Green Belt and safeguarded for future development.

Object

Representation ID: 1484

Received: 10/12/2021

Respondent: Amadis Holdings Ltd

Agent: PlanIt

Insufficient land released from the Green Belt to meet para 140 of NPPF. Additional land needs to be released for development now, and the omission of the identification of further safeguarded is significant and should be rectified.
Policy DS1 – penultimate paragraph is inappropriate and more restrictive than NPPF. No policy justification for limited infilling and control of building heights. Other forms of inappropriate development as per para 150 of NPPF have been omitted. Penultimate paragraph of policy should be removed and policy should refer back to NPPF.

Object

Representation ID: 1485

Received: 10/12/2021

Respondent: Amadis Holdings Ltd

Agent: PlanIt

Housing Requirement - Housing requirement proposed is below the standard method figure that is derived from the Council's own HMA. HMA fails to correctly factor in affordable housing need and whether an uplift is required. The 4000 dwellings will have its own affordable housing requirement separate to that of South Staffordshire. No consideration given to uplifting the standard method to take account of economic growth aspirations and increasingly ageing population.
Strategic Housing Growth Study is out of date and does not use the standard method. there is more up to date evidence available on the housing shortfall.
Birmingham's assertion that their shortfall has reduced should be treated with caution. Together with the Black Country shortfall 66139 dwellings should be considered the absolute minimum. South Staffs proposes 4% of the shortfall, this is unacceptable. Should be taking more given the functional relationship with the Black Country. Insufficient capacity in other GBHMA authorities to absorb shortfall and South Staffordshire should be taking a greater proportion given its functional relationship with the Black Country. The plan’s spatial strategy for housing should be predicated on making allocations adjacent to the conurbation.

Support

Representation ID: 1507

Received: 10/12/2021

Respondent: Amadis Holdings Ltd

Agent: PlanIt

It is sensible for such schemes to be identified through the plan making process given the lead in times and complex nature of such projects. It is our view that it is more sustainable to extend existing settlements in the first instance where services and facilities exist, including the allocation of urban extensions.

Object

Representation ID: 1513

Received: 10/12/2021

Respondent: Amadis Holdings Ltd

Agent: PlanIt

The housing requirement should be increased significantly, and new allocations identified adjacent to the edge of the conurbation. Land at Yew Tree Lane (sites 243 and 504) are identified as being ‘potentially suitable’ for development in the SHELAA.
The sites are in a very sustainable location and immediately adjoin the built-up edge of Wolverhampton within a short distance of a number of services and facilities.
The development of these sites would not extend the existing pattern of development further west than existing development to the north and south.
The Green Belt Study 2019, parcel S46, notes ” reduction in separation ( …between Perton and Tettenhall) would increase the extent to which the settlements are perceived to form part of the large built-up area. However there are a few locations within the narrower strips/wedges of Green Belt that separate villages (e.g. Perton) from the main body of the conurbation that are too contained to make a strong contribution, regardless of openness. These parcels of land would have a limited impact on the purposes of Green Belt. There are clear and defensible boundaries; a high-quality residential
development scheme could be delivered; principal points of access to both parcels of land would be from Wrottesley Road and an opportunity to create a secondary access point on to Yew Tree Lane. A significant area of public open space could be created on the sites’ western edge and could provide 120-140 dwellings and would make a significant contribution to the housing requirement.

Object

Representation ID: 1514

Received: 10/12/2021

Respondent: Amadis Holdings Ltd

Agent: PlanIt

HC1 - do not support direction of travel for HC1. 75% of houses to be 3 bedrooms or less is too prescriptive, policy needs to more flexible.
Object to the principle of refusal of schemes with a disproportionate amount of larger homes. Disproportionate is not clear and disregards the demand for executive style housing in South Staffordshire to retain and attract higher income households.
HC11 - there is no evidence to support the proposal to meet nationally described space standards.
The imposition cannot be justified in policy terms and are not appropriate in South Staffordshire